16 CFR Part 306; Automotive Fuel Ratings, Certification and Posting; Project No. R811005
As a member of the American Motorcyclist Association, a Motorcycle Safety Foundation RiderCoach, and a professional technical communicator, I am writing to express my concerns about the Federal Trade Commission's proposed rule regarding requirements for labeling ethanol blends of more than 10 percent. The misfueling mitigation plan says: "Retail stations that wish to use this new configuration must provide a fuel pump with at least one dedicated hose and nozzle dispensing a gasoline-ethanol blended fuel containing no more than 10 volume percent ethanol (i.e. E10 or lower). These retail stations must also prominently affix a new label to its blender pumps which says "Passenger Vehicles Only. Use in Other Vehicles, Engines and Equipment May Violate Federal Law." … Retails stations must also post additional signage informing consumers of the availability and location of the dedicated E10 (or lower) fuel pump." That's all? Labels and signs? Have you really taken a look at all of the labels and signs posted at the place where you fill your car? This is not adequate. I write instruction and maintenance manuals for a living. One of the first things all good writers do is an audience analysis. We write specifically for the lowest common denominator so all users can understand the instructions. We understand how the material will be used and which approaches are likely to be the most successful in communicating information. Gas pumps are used by people from all socioeconomic levels. They may or may not be educated; they might not be able to read English well - or at all. In a perfect world, everyone reads the manual completely, everyone follows the rules, and everyone is equal. This is not a perfect world. And this stuff is not E10. The EPA says that motorcycles, older cars, heavy-duty gasoline engines, and "nonroad products" are not permitted to use E15. If I put it in my motorcycle tank, I understand that there's a very good chance that it won't just reduce my mpg; it will cause damage to my bike. I strongly encourage you to be more specific in your communication plans for dispensing E15. - Consider how to make the labels and signs noticeable and easy to understand. Using a standardized color, size, and font is an excellent practice.The proposed orange will be easily recognizable. I understand this applies only to the labels and not signage. If you require both of these to be placed in the same locations at every pump, people will tend to recognize them sooner. - I understand that the wording on the label is to use the terms "passenger vehicles" and "other vehicles." This proposed phrasing is very likely to cause confusion. I realize that the NHTSA defines passenger vehicles as cars and light trucks. I also know that many people are not aware of this specific definition and consider a passenger vehicle as anything that carries people - including motorcycles, ATVs, and buses. "Other vehicles" is conspicuously vague. If your goal is to do the minimum necessary, I'd say you've succeeded. If your genuine goal is to communicate this warning to protect the general population, I don't think you're quite there yet. "…2001 and newer cars and light trucks (gross vehicle weight no greater than 8,500 pounds)" is much clearer. - Allowing for rounding the volume percentage of ethanol in the fuel to the nearest factor of 10 concerns me. This gives vendors permission to sell 14.5% ethanol fuel labeled as 10%. I fully support retailers making a profit, but there is a big difference between affecting one's fuel economy with 10% ethanol and a person unwittingly filling up with an ethanol percentage higher than 10 and potentially causing serious damage to his vehicle, affecting his personal safety, and voiding his vehicle's warranty. Please consider these reasons to be more specific with this communication plan. Thank you for your time and the opportunity to comment on this issue.